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Compliance review and monitoring documentation / work papers retention

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  • #37286
    TheBank
    Participant

    How long is it recommended to keep compliance review support, work papers, etc…?

    #37288
    kboatwright
    Participant

    As good rule of thumb, IMO, outside of BSA/AML requirements, has been to maintain workpapers and documentation at a minimum of exam cycle to exam cycle. Or for five years to align with the BSA testing. However, with recent enforcement actions depicting the Regulators using HMDA data that is 5-6 years old in Fair Lending and redlining cases. You may want to consider maintaining testing documentation for a period of 7 years.

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